Description of Firm Dempsey Investment Management, LLC is a registered investment adviser primarily based in Burlington, Vermont. We are organized as a limited liability company ("LLC") under the laws of the Securities and Exchange Commision. We have been providing investment advisory services since 04/01/2005. We are primarily owned by DonaldDempsey.
The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to Dempsey Investment Management, LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
Financial Planning Services We offer limited financial planning services to those in need of such service in conjunction with our portfolio management services or as a stand-alone service. Our limited financial planning services normally address areas such as general cash flow planning, retirement planning, and insurance analysis. The goal of this service is to assess your financial circumstances in order to more effectively develop a financial plan or to provide guidance for general planning strategies.
Portfolio Management Services We offer discretionary portfolio management services. Our investment advice is tailored to meet your needs and investment objectives. In limited circumstances we will offer our services on a non-discretionary basis. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. We may also offer non-discretionary portfolio management services. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis.
As part of our portfolio management services, we may use one or more third party money manager (TPMM) to manage all or a portion of your account on a discretionary basis. The TPMM(s) may use one or more of their model portfolios to manage your account. We will regularly monitor the performance of your accounts managed by TPMM(s), and may hire and fire any TPMM without your prior approval. You may pay a fee to the TPMM in addition to the fee you pay us for our services.
As part of our portfolio management services we may invest your assets according to one or more model portfolios developed by our firm. These

models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of securities in their account. In such cases, this may prevent a client from investing in certain models that are managed by our firm.
Wrap Fee Programs We do not participate in any wrap fee program.
Types of Investments We offer advice on primarily equity securities, mutual fund shares, and ETFs. Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Assets Under Management As of January 17, 2024, we provide continuous management services for $126,492,126 in client assets on a discretionary basis, and no assets on a non-discretionary basis.